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Motion for Continuance

Motion for Continuance

150 150 Cohen, Bradshaw, Rothstein & Klein

DEFENDANT, by and through undersigned counsel and pursuant to Rule 3.190(g) of the Washington DC Rules of Criminal Procedure, requests this Honorable Court to continue the above-captioned case.  As grounds for this Motion, Defendant states as follows:

  1. The Defendant is charged with one count of Battery Domestic Violence (M1) and is scheduled for Jury Trial on June 10, 2011.
  2. The undersigned has learned that the alleged victim, Jill Smith, has out-of-county felony convictions.
  3. Evidence of the alleged victim’s criminal history is essential to the proper defense of Defendant’s case.
  4. The undersigned has submitted investigative requests with the goal of obtaining certified copies of any and all felony convictions or convictions for misdemeanors involving dishonesty.
  5. The undersigned will not, on Defendant’s scheduled trial date, have certified copies of the judgments of conviction pertaining to the alleged victim.  Additional time is therefore needed to obtain the certified copies.

WHEREFORE, the undersigned counsel respectfully requests this Honorable Court grant this Motion for Continuance.